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Home My WebLink About05-4177 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff No: OS -'1/77 c; 0; t:T02-~ vs. COMPLAINT IN CIVIL ACTION THOMAS PREVITE SR Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 04180178 CEPit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff vs. Civil Action No THOMAS PREVITE SR Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, CACV OF COLORADO is a corporation with offices at 370 17TH ST. ,SUITE 5000 DENVER, CO 80202 . 2. Defendant is an adult individual{s) residing at the address listed below: THOMAS PREVITE SR 59 GARDEN PKWY CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number 4050860100511177 . 4. Defendant made use of said credit card and has a current balance due of $11585.67 , as of July 13, 2005 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 6.000% per annum on the unpaid balance from July 13, 2005 . A copy of Plaintiff's Statement of Acco unt is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant THOMAS PREVITE SR individually , in the amount of $11585.67 with continuing interest thereon at the rate of 6.000% per annum from July 13, 2005 plus costs. This law firm is a debt collector a empting to collect this debt for our client and any information obtained will be used for that purpose. . Warmbrodt,42524 , WEINBERG & REIS CO., L.P.A. enth Avenue, Suite 2718 urgh, PA 15219 434-7955 E 412-338-7130 4 80178 CEPit KMJ VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S Section 4904 relating to unsworn falsifications to ~\)) I, .7.1) ~ yJ- of (Title) b ttVLitV\t S't'/pNVl S (Na e) , C At IJ g~ (,\/OjA (I Ii ) LU. ( ompany) authorities, that he/she is plaintiff herein, that he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. b.~~~ (Sign ture) 04180178 CEPit KMJ This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. , D ~ 1j \( ~ U( ~ U( ,...., <;(, 10 D- o c? c:.:;;> ~~; cf' ~..." 'Iv ~ .,.,.. r-r-: "c ("11-- ..a G""J f'n Is' - ;0,9 r) U1 '.:-~\~- -,- , g _.._ 11 0 ~" '2- -",' ~.;: ~~ ....(1 ~-,- ':::!, '---L.. '-:? 'J>' <-' ?l ..0 SHERIFF'S RETURN - REGULAR CASE NO: 2005-04177 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACV OF COLORADO VS PREVITE THOMAS SR WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PREVITE THOMAS SR the DEFENDANT , at 1350:00 HOURS, on the 2nd day of September, 2005 at 59 GARDEN PKWY CARLISLE, PA 17013 by handing to THOMAS PREVITE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 4.00 .00 10.00 .00 32.00 "';f.,,,,"-('?,/O/ . .. .O~ ~. d' ~._<:;;~,~-,,:;,,~'~--;:"'-~-:~'"f. ~r.ff ~ /' -, . ...., . R. Thomas Kline me this .J ( day of 09/06/2005 WEL~W:;Z~~ ' Deputy S eriff Sworn and Subscribed to before A.D. ..~ ., 1 .. lN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff No. 05-4177CIVILTERM vs. PRAECIPE TO SETTLE, DISCONT1NUE AND END WITHOUT PREJUDICE TO REFILE THOMAS PREVITE SR Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#04180178 " .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CACV OF COLORADO Plaintiff vs. Civil Action No. 05-4177CIVIL TERM THOMAS PREVITE SR Defendant PRAECIPE TO SETTLE. DISCONTINUE AND END WITHOUT PREJUDICE TO REFlLE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Kindly settle. discontinue and end without prejudice to refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. ,c::::::::----. By: Jam PA I.D #42524 WELTMAN INBERG & REIS CO.. L.P.A. 2718 Kop rs uilding 436 Seve th venue Pittsbur h, A 15219 (412) 434-7955 SWORN TO AND SUBSCRIBED li+h before me this ~y ARY Ie " COMMONWEALTH OF PENNSYLVANIA Notarial Seal Heidi J. Kally, Notary Public City 01 Pittsburgh, Allegheny Coun My Commlsaion Expi.... Nov. 4, wirs Member, Ponn'Ylv4f\la As,oolatlon of Notarla. of .'\', ,.--', '. t-:..':: --'.... .------